REV02472

• Permit No: C1981041
• IBM Index Class Name: Revision
• Doc Date: 10/22/2001
• Doc Name: POWDERHORN COAL CO MR-52 REVISE RECLAMATION SCHEDULE PN C-81-041
• From: J E STOVER & ASSOCIATES
• To: DMG
• Type & Sequence: MR52
• Media Type: D
• Archive: No

' J. E. STOVER & ASSOCIATES
2768 COMPASS DRIVE, SUITE 101
GRAND JUNCTION, COLORADO 81506
PHONE: [phone], FAX [phone]
MINE ENGINEERING RECEIVE D
MINE RECLAMATION
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October 18, 2001
pivision of Minerals and Geology
David Berry
Division of Minerals and Geology
101 South 3rtl Suite 301
Grand Junction, CO 81501
Re: Powderhorn Coal Company
MR-052 Revise Reclamation Schedule
Permit C-81-041
Dear Mr. Berry:
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CIVIL ENGINEERING
CONSi. MANAGEMENT
Powderhorn Coal Company is in receipt of your letter dated September 28, 2001.
Powderhorn appreciates the Division's approval of its minor revisions pertaining to the
powder and cap magazine, the culvert under Excel Energy Road and the reclamation
schedules for CRDA-1. Powderhorn will submit a revised Figure 14-1 to reflect the
schedule modification for CRDA-1.
The letter indicates that the Division is unable to approve certain changes as minor
revisions at this time based on the view that a land use change is being requested. A list
of these requested changes, which largely relate to delays in demolition, is contained at
pages 1 and 2 of your letter. W e believe that there is a misunderstanding in what has been
requested by Powderhorn's minor revision.
The minor revision simply is a request for a delay to initiate and complete demolition of
certain buildings and final reclamation activities of specified, discrete areas. The company
has not submitted and is uncertain whether it will submit a land use change. It merely
seeks an extension of time to determine the viability of using the remaining structures for
commercial purposes. Structures with no long term value already have been demolished.
Powderhorn believes that there will be no harm or risk to the state from this delay. We
believe that the value of the property will be significantly enhanced by maintaining the
remaining buildings. The property has sand and gravel assets and other commercial
values. Powderhorn has initiated the process of obtaining appraisal information concerning
the value of the land with and without the structures in question. In the event that the value
of the land plus structures exceeds the value of the land by more than the cost of
demolition and reclamation, there would be no harm or risk to the state by allowing the
buildings to remain pending a determination of the commercial assessment. Furthermore,
given that these buildings have great potential for uses other than mining, it seems